European Accessibility Act & WCAG 2.1 AA. What really applies?

From 28 June 2025, Directive (EU) 2019/882 – the European Accessibility Act (EAA) – comes into full effect in all EU Member States, introducing new digital accessibility obligations.

However, the question is: which businesses are actually required to bring their websites into compliance with the “WCAG 2.1 AA standard” mandated by the Directive? And why are small businesses panicking at the prospect of “hefty fines”?

Before we dive into an analysis of what really applies, let’s first clarify the below terms, which will be rather unfamiliar to most people.

European Accessibility Act (EAA) – Directive (EU) 2019/882

This is a European directive—a law—aimed at ensuring that digital products and services (websites, apps, POS terminals, etc.) made available in EU Member States are accessible to persons with disabilities: visual, hearing, motor or cognitive impairments. By incorporating the “WCAG 2.1 AA standard” into websites, the Directive establishes minimum accessibility requirements, with the goal of equal access to the internet and digital services for all.

WCAG 2.1 AA Standard

This is a technical standard that defines how a website must be designed so as to be accessible to people with disabilities.

The Misunderstanding

Here’s where the confusion starts: many believe that from June 2025 onward, all websites must comply with “WCAG 2.1 AA” under the European Directive.

In fact, it does not apply to every business! It applies only to those offering digital products or services that are “critical to the public”, such as:

• E-commerce sites (e-shops)
• Online banking services
• Telecommunications provider platforms
• Ticketing apps or websites
• Streaming and e-book services
• POS terminals and related software
• And, of course, hotel websites, as long as they have an online booking engine.

Even if your business falls into one of the categories above, you may still be exempt from the Directive if you qualify as a micro-business.

Based on these criteria, the vast majority of Greek businesses with a website are legally exempt from the obligation to comply with the EAA—and hence from any potential fines in case of complaint.

Many web-development firms are sending generic emails to clients (and beyond) without clarifying the basic conditions:

• What the European Directive covers
• Whom it applies to
• Who is exempt

Result: undue anxiety, intense pressure and the spread of misinformation among businesses who have no legal obligation to comply.

Even if I’m Not Required to Comply, Is It Worth Doing Voluntarily?

• Access to EU funding programs (ESPA)
  In recent years, any implementation under an EU ESPA program that involves digital enhancement requires WCAG compliance.
• Better search-engine rankings
  Clean, well-structured HTML helps search engines (e.g. Google) “understand” your site’s content more effectively.
• More comfortable navigation for everyone
  Users with visual or motor impairments can easily navigate using a keyboard or other assistive tools.
• Enhanced reputation and credibility
  A business that shows respect for visitors and potential customers—regardless of ability—earns positive recognition in the market.
• Preparation for future growth
  If you expand and legislation later mandates compliance, you’ll have already completed most of the process.
• Demonstrating social responsibility
  You show tangible support for persons with disabilities and promote a positive social message—values appreciated by the public and that bolster your reputation.

Checking Your Website’s Accessibility

If you’re still unsure about the above, or if you’re a business required to comply, you can contact us and we’ll be happy to guide you through the next steps.